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Float on Imaged Items

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Question: 
How will float days be determined on imaged items?
Answer: 

There are three answers, depending on what you mean by "float."

If you are referring to the actual time it takes to collect a check that has been truncated and processed as an image, that will depend on the efficiencies of the system, and those will improve as image-exchange technology takes hold.

If you are referring to the time period before which your bank is able to use the funds represented by a check you've placed in the collection stream, that depends on the availability schedule you receive from the Fed or other collecting bank (correspondent).

If, as I suspect, you are referring to Reg. CC rules, there's nothing changed in those rules yet. You can treat the truncated/imaged check just like the original for the purpose of determining your bank's availability and hold periods under Regulation CC.

The Fed realizes that, under current hold period maximums, many checks -- both local and non-local -- are still returned after the depositary bank has released holds. However, it's likely that, at some point, the efficiencies brought by Check 21 and image-exchange will work to correct that problem. The Fed is also charged with reporting to Congress on the improvements to the check collection system and how they affect availability of deposited funds from transit checks. We may see Regulation CC hold periods "truncated" somewhat as an eventual result.

But that isn't happening yet.

First published on BankersOnline.com 08/02/04

First published on 08/02/2004

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